ECHA flags 28 substances for evaluation over next three years

What is CoRAP?

• The Community Rolling Action Plan (CoRAP) belongs to the “E” in REACH (registration, evaluation, authorization, and restriction of chemicals; Regulation (EC) 1907/2006). Laid out in Chapter 2 of Title VI, CoRAP is part of REACH’s substance evaluation procedure (as opposed to dossier evaluation) to determine if certain chemicals pose a risk to people or the environment. Member-state competent authorities and the European Chemicals Agency (ECHA) must select and prioritize substances annually for evaluation over a three-year period on an ongoing basis. Individual member states are assigned to carry out the evaluations of the listed substances. Those considered of highest priority are evaluated during the current year, while lower priority substances are scheduled for evaluation in the subsequent second and third years of the three-year period.
• Substances are identified and prioritized for CoRAP using a risk-based approach. Selection is based on three criteria listed in Article 44(1): (1) information available on the chemical’s known or suspected intrinsic hazards; (2) exposure information, including use applications, use settings and conditions, and typical users; and (3) the tonnage band in which the chemical is registered under REACH. Substances that are suspected of exhibiting more hazards of concern – like persistence, bioaccumulation, and toxicity (PBTs), or carcinogenicity, mutagenicity, and toxicity to reproduction (CMRs), or respiratory sensitization – which also have a wider and more dispersive use and higher probability of exposure, are more likely to be selected for CoRAP listing.
• Obtaining more information is key to determining whether the CoRAP-listed substances truly pose risks that may need to be further managed under the EU’s regulatory risk management (RRM) framework. This is where industry gets involved: the member state assigned to evaluate substances will frequently request more information from registrants, often extending beyond the scope of information required for registration under REACH.
• Being listed in CoRAP does not necessarily mean a substance will eventually be subject to further RRM measures. Rather, the CoRAP process is focused on clarifying a concern about substances posing a risk. This may be confirmed or dismissed through substance evaluation.

ECHA publishes the 2024 update to CoRAP

• On March 19, ECHA published the list of CoRAP substances to be evaluated during 2024, 2025 and 2026. This follows adoption of the draft list by the agency’s Member State Committee (MSC) on February 13. Below is the final list, which, when compared to CoRAP for 2023-2025, encompasses 11 new substances in addition to the 17 substances that were already present on the list (for a total of 28).
• The first 10 substances listed below have been prioritized for evaluation in 2024, including four substances that the Danish competent authority will likely evaluate as a group, given their apparent structural similarity.
• Evaluation of the next 13 entries is scheduled for 2025, including two groups of substances likely to be addressed in joint evaluations, also because of their apparent structural similarity. Spain and France respectively have been tapped to evaluate these groups, represented by the following identifiers: (1) EC Nos. 701-246-8, 701-463-8; and (2) CAS RNs 99-62-7, 100-18-5, and EC No. 905-459-9.
• The five remaining substances on the list are scheduled for 2026 and have been assigned to France and the Netherlands.
• Finally, one substance – tris[2-chloro-1-(chloromethyl)ethyl] phosphate – whose evaluation Germany was assigned to conduct in 2024, has been withdrawn. This withdrawal comes after the authorities determined that the substance must first undergo a compliance check under dossier evaluation. ECHA states that if concerns about related risks persist following this compliance check, the substance may be placed back on the CoRAP list.

Next steps

• Registrants are encouraged to verify whether their substances are on the 2024-2026 CoRAP list. Of highest importance are the first 10 entries earmarked for evaluation in 2024, since registrants of these substances will be affected the soonest.
• ECHA recommends that companies which have registered any of the first 10 substances under REACH initiate early communication with co-registrants and the evaluating member-state competent authority (eMSCA) for details on the upcoming evaluation. Contact details for the eMSCAs are given in the final column of the list of CoRAP substances.
• The eMSCAs assigned to the 28 listed substances now have 12 months to complete the respective evaluations. During this time, they will determine whether additional information needs to be obtained from registrants to confirm whether use of the substances poses a risk to human health or the environment. If the evaluation concludes that further information to clarify this risk is not needed and no concerns exist, the evaluation is concluded without additional information requests.
• If the eMSCA finds that additional information is necessary to clarify the status of the CoRAP substance, affected registrants can expect to receive a draft substance evaluation decision requesting additional information after the 12-month evaluation. In these cases, registrants are given opportunity to initially comment on the requested information, which is often for data that must be generated through further testing.
• The authorities will issue a final decision on the scope of any information requested, based on the registrant responses. This final decision will include a deadline by which the companies of the registered substances are required to submit the requested information.

Key Documents and Dates

• Community Rolling Action Plan (CoRAP) update covering the years 2024, 2025 and 2026 (March 19, 2024)
• Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)